IR 05000483/2014005
| ML15036A620 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 02/04/2015 |
| From: | O'Keefe N NRC/RGN-IV/DRP/RPB-B |
| To: | Diya F Union Electric Co |
| O'Keefe N | |
| References | |
| IR 2014005 | |
| Download: ML15036A620 (73) | |
Text
UNITED STATES ary 4, 2015
SUBJECT:
CALLAWAY PLANT - NRC INTEGRATED INSPECTION REPORT 05000483/2014005
Dear Mr. Diya,
On December 31, 2014, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Callaway Plant. On January 7, 2015, the NRC inspectors discussed the results of this inspection with you and other members of your staff. Inspectors documented the results of this inspection in the enclosed inspection report.
NRC inspectors documented one finding of very low safety significance (Green) in this report.
This finding involved a violation of NRC requirements. Further, inspectors documented two licensee-identified violations which were determined to be of very low safety significance in this report. The NRC is treating these violations as non-cited violations (NCVs) consistent with Section 2.3.2.a of the NRC Enforcement Policy.
If you contest the violations or significance of these NCVs, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region IV; the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC resident inspector at the Callaway Plant.
If you disagree with a cross-cutting aspect assignment in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the Regional Administrator, Region IV; and the NRC resident inspector at the Callaway Plant.
In accordance with Title 10 of the Code of Federal Regulations (10 CFR) 2.390, Public Inspections, Exemptions, Requests for Withholding, a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRCs Public Document Room or from the Publicly Available Records (PARS) component of the NRC's Agencywide Documents Access and Management System (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely,
/RA/
Neil OKeefe, Branch Chief Project Branch B Division of Reactor Projects Docket Number: 50-483 License Number: NPF-30
Enclosure:
Inspection Report 05000483/2014005 w/ Attachments:
1. Supplemental Information 2. Items Requested for the O
REGION IV==
Docket: 05000483 License: NPF-30 Report: 05000483/2014005 Licensee: Union Electric Company Facility: Callaway Plant Location: Junction Highway CC and Highway O Steedman, MO Dates: September 20 through December 31, 2014 Inspectors: T. Hartman, Senior Resident Inspector Z. Hollcraft, Resident Inspector I. Anchondo, Reactor Inspector L. Brandt, Project Engineer J. Buchanan, Physical Security Inspector P. Elkmann, Senior Emergency Preparedness Inspector M. Langelier, Project Engineer J. ODonnell, Health Physicist L. Ricketson, P.E., Senior Health Physicist W. Sifre, Senior Reactor Inspector C. Stott, Project Engineer F. Thomas, Project Engineer Approved By: N. OKeefe Chief, Project Branch B Division of Reactor Projects-1- Enclosure
SUMMARY
IR 05000483/2014005; 09/20/2014 - 12/31/2014; Callaway Plant, Integrated Resident and
Regional Report; Maintenance Effectiveness and Reactor Vessel Head Replacement.
The inspection activities described in this report were performed between September 20 and December 31, 2014, by the resident inspectors at the Callaway Plant and inspectors from the NRCs Region IV office. One finding of very low safety significance (Green) is documented in this report. This finding involved a violation of NRC requirements. Additionally, NRC inspectors documented two licensee-identified violations of very low safety significance. The significance of inspection findings is indicated by their color (Green, White, Yellow, or Red), which is determined using Inspection Manual Chapter 0609, Significance Determination Process. Their cross-cutting aspects are determined using Inspection Manual Chapter 0310, Aspects within the Cross-Cutting Areas. Violations of NRC requirements are dispositioned in accordance with the NRC Enforcement Policy. NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process.
Cornerstone: Mitigating Systems
- Green.
Inspectors reviewed a self-revealing non-cited violation of 10 CFR Part 50,
Appendix B, Criterion XVI, Corrective Actions, involving the licensees failure to correct a condition adverse to quality. Specifically, an extent of condition review for a failed gasket identified that other safety related gaskets installed in the plant were potentially less reliable; however, no action was taken. One of these gaskets failed on October 17, 2014, and caused a 52 gpm leak from the end bell of the train B control room air conditioning chiller affecting the reliability of the train. This issue was entered into the licensees corrective action program as Callaway Action Request 201409335. One remaining improperly installed gasket was evaluated and operability was justified.
The inspectors determined the failure to correct a condition adverse to quality was a performance deficiency. This performance deficiency was more than minor because it was associated with and adversely affected the equipment performance attribute of the Mitigating Systems Cornerstone, and affected the cornerstone objective to ensure the reliability of systems that respond to initiating events to prevent undesirable consequences. Specifically, during the period of November 2013 to October 2014, the failure to correct an improperly installed gasket on a control room air conditioning unit resulted in reduced reliability of the safety related system. Using NRC Inspection Manual 0609, Appendix A, Exhibit 2, Mitigating Systems Screening Questions, the finding was determined to be of very low safety significance (Green) because it did not affect the design or qualification of the system, did not result in a loss of system function, did not represent a loss of function of a single train for greater than its technical specifications allowed outage time, and did not cause the loss of function of one or more non-technical specification trains of equipment designated as high safety-significance.
The finding has an Evaluation cross-cutting aspect within the problem identification and resolution area because the licensee failed to thoroughly evaluate and ensure that the resolution addressed the extent of condition commensurate with its safety significance.
Specifically, the extent of condition for improperly installed safety related gaskets was identified; however, the evaluation of the degraded condition did not assess the significance and cause corrective actions to be scheduled in a timely manner commensurate with that significance [P.2]. (Section 1R12)
Licensee-Identified Violations
Two violations of very low safety significance were identified by the licensee and have been reviewed by the inspectors. Corrective actions taken or planned by the licensee have been entered into the licensees corrective action program. These violations and associated corrective action tracking numbers are listed in Section 4OA7 of this report.
PLANT STATUS
Callaway began the inspection period at 100 percent power. On October 6, 2014, the licensee began coasting down at the end of the operating cycle and on October 11 the licensee shut the plant down to start Refueling Outage 20. The reactor was restarted on November 21 and the plant was returned to full power on November 26. On December 3 the plant tripped due to an electrical fault experienced on the excitation transformer of the main generator. Callaway remained shutdown until December 5 when the reactor was restarted. The plant returned to 100 percent power on December 7. Callaway operated at full power for the remainder of the inspection period.
REPORT DETAILS
REACTOR SAFETY
Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity
1R01 Adverse Weather Protection
.1 Readiness for Seasonal Extreme Weather Conditions
a. Inspection Scope
On November 14, 2014, the inspectors completed an inspection of the stations readiness for seasonal extreme weather conditions. The inspectors reviewed the licensees adverse weather procedures for winter readiness and evaluated the licensees implementation of these procedures. The inspectors verified that prior to the onset of cold weather and snow; the licensee had corrected weather-related equipment deficiencies identified during the previous winter.
The inspectors selected two risk-significant systems that were required to be protected from cold weather:
- refueling water storage tank
- condensate storage tank The inspectors reviewed the licensees procedures and design information to ensure the systems or components would remain functional when challenged by cold weather. The inspectors verified that operator actions described in the licensees procedures were adequate to maintain readiness of these systems. The inspectors walked down portions of these systems to verify the physical condition of the adverse weather protection features.
These activities constituted one sample of readiness for seasonal adverse weather, as defined in Inspection Procedure 71111.01.
b. Findings
No findings were identified.
.2 Readiness for Impending Adverse Weather Conditions
a. Inspection Scope
Since high wind conditions were forecast in the vicinity of the facility for October 1, 2014, the inspectors completed an inspection of the stations readiness for impending adverse weather conditions. The inspectors reviewed plant design features, the licensees procedures to respond to tornadoes and high winds, and the licensees implementation of these procedures. The inspectors evaluated operator staffing and accessibility of controls and indications for those systems required to control the plant.
These activities constituted one sample of readiness for impending adverse weather conditions, as defined in Inspection Procedure 71111.01.
b. Findings
No findings were identified.
1R04 Equipment Alignment
.1 Partial Walkdown
a. Inspection Scope
The inspectors performed partial system walk-downs of the following risk-significant systems:
- October 30, 2014, train A spent fuel pool cooling
- November 4, 2014, train A emergency diesel generator air start system
- November 19, 2014, train B motor-driven auxiliary feedwater pump The inspectors reviewed the licensees procedures and system design information to determine the correct lineup for the systems. They visually verified that critical portions of the trains were correctly aligned for the existing plant configuration.
These activities constituted three partial system walk-down samples as defined in Inspection Procedure 71111.04.
b. Findings
No findings were identified.
.2 Complete Walkdown
a. Inspection Scope
On November 11, 2014, the inspectors performed a complete system walk-down inspection of the cold overpressure mitigation system. The inspectors reviewed the licensees procedures and system design information to determine the correct lineup for the existing plant configuration. The inspectors also reviewed outstanding work orders, completed work orders, open condition reports, and other open items tracked by the licensees operations and engineering departments. The inspectors then visually verified that the system was correctly aligned for the existing plant configuration.
These activities constituted one complete system walk-down sample, as defined in Inspection Procedure 71111.04.
b. Findings
No findings were identified.
1R05 Fire Protection
Quarterly Inspection
a. Inspection Scope
The inspectors evaluated the licensees fire protection program for operational status and material condition. The inspectors focused their inspection on four plant areas important to safety:
- October 8, 2014, auxiliary building level 2047, area A-19
- November 17, 2014, reactor building, area RB-1
- December 23, 2014, train A safety injection and centrifugal charging pumps, area A-2
- December 30, 2014, auxiliary shutdown panel, areas A-28 and A-33 For each area, the inspectors evaluated the fire plan against defined hazards and defense-in-depth features in the licensees fire protection program. The inspectors evaluated control of transient combustibles and ignition sources, fire detection and suppression systems, manual firefighting equipment and capability, passive fire protection features, and compensatory measures for degraded conditions.
These activities constituted four quarterly inspection samples, as defined in Inspection Procedure 71111.05.
b. Findings
No findings were identified.
1R06 Flood Protection Measures
a. Inspection Scope
On December 23, 2014, the inspectors completed an inspection of the stations ability to mitigate flooding due to internal causes. After reviewing the licensees flooding analysis, the inspectors chose one plant area containing risk-significant structures, systems, and components that were susceptible to flooding:
- Train A and B emergency core cooling system pump rooms The inspectors reviewed plant design features and licensee procedures for coping with internal flooding. The inspectors walked down the selected areas to inspect the design features, including the material condition of seals, drains, and flood barriers. The inspectors evaluated whether operator actions credited for flood mitigation could be successfully accomplished.
b. Findings
No findings were identified.
1R08 Inservice Inspection Activities
The activities described in subsections 1 through 4 below constitute completion of one inservice inspection sample, as defined in Inspection Procedure 71111.08.
.1 Non-destructive Examination Activities and Welding Activities
a. Inspection Scope
The inspectors directly observed the following non-destructive examinations:
System Weld Identification Examination Type Feedwater 2AE05F021 Ultrasonic Steam Generator A ABHV0014 Ultrasonic Main Steam Isolation Valve Pressurizer Skirt 2-TBB03-SKIRT-W-IWA Magnetic Particle Weld Steam Generator A ABHV0014 Phased Array Ultrasonic Main Steam Isolation Valve Pressurizer Spray 2-TBB03-SPR-07000267-SWOL Phased Array Ultrasonic Nozzle Weld Overlay Pressurizer Relief 2-TBB03-REL-07000264-SWOL Phased Array Ultrasonic Nozzle Weld Overlay The inspectors reviewed records for the following non-destructive examinations:
System Weld Identification Examination Type Chemical and 2-BG-02-H009 Visual (VT-3)
Volume Control System Weld Identification Examination Type Reactor Vessel 2-RV-302-121-A Ultrasonic, Eddy Current Inlet Nozzle Safe End Weld Reactor Vessel 2-RV-302-121-B Ultrasonic, Eddy Current Inlet Nozzle Safe End Weld Reactor Vessel 2-RV-302-121-B Ultrasonic, Eddy Current Inlet Nozzle Safe End Weld Reactor Vessel 2-RV-302-121-B Ultrasonic, Eddy Current Inlet Nozzle Safe End Weld During the review and observation of each examination, the inspectors observed whether activities were performed in accordance with the ASME Code requirements and applicable procedures. The inspectors also reviewed the qualifications of all non-destructive examination technicians performing the inspections to determine whether they were current.
The inspectors reviewed records for the following welding activities:
System Weld Identification Weld Type Examination Type Auxiliary 13004618/500 Gas Tungsten Magnetic Particle, Feedwater Arc Weld Liquid Penetrant Residual Heat 13004624/010 Gas Tungsten Liquid Penetrant, Removal Arc Weld Radiography High Pressure 13004626/010 Gas Tungsten Radiography Coolant Injection Arc Weld Essential Service 14003510/407 Gas Tungsten Magnetic Particle Water Arc Weld The inspectors reviewed whether the welding procedure specifications and the welders had been properly qualified in accordance with ASME Code Section IX requirements.
The inspectors also determined whether essential variables were identified, recorded in the procedure qualification record, and formed the bases for qualification of the welding procedure specifications.
b. Findings
No findings were identified.
.2 Vessel Upper Head Penetration Inspection Activities
a. Inspection Scope
The licensee replaced the reactor vessel upper head. All inspection activities associated with the upper head replacement are documented in Section 4OA5. Therefore, the inspectors determined this section of Inspection Procedure 71111.08 was not applicable.
b. Findings
No findings were identified.
.3 Boric Acid Corrosion Control Inspection Activities
a. Inspection Scope
The inspectors reviewed the licensees implementation of its boric acid corrosion control program for monitoring degradation of those systems that could be adversely affected by boric acid corrosion. The inspectors reviewed the documentation associated with the licensees boric acid corrosion control walk-down as specified in Procedure EDP-ZZ-01004, Boric Acid Corrosion Control Program, Revision 17, and Procedure QCP-ZZ-05048, Boric Acid Walkdown for (Reactor Coolant System) RCS Pressure Boundary, Revision 8. The inspectors reviewed whether the visual inspections emphasized locations where boric acid leaks could cause degradation of safety-significant components, and whether evaluations used corrosion rates applicable to the affected components and properly assessed the effects of corrosion-induced wastage on structural or pressure boundary integrity. The inspectors observed whether corrective actions taken were consistent with the ASME Code, and 10 CFR Part 50, Appendix B requirements.
b. Findings
No findings were identified.
.4 Steam Generator Tube Inspection Activities
a. Inspection Scope
The licensee did not perform inspections of the steam generator tubes. No inspections were required this outage. No primary side inspections were performed. Therefore, the inspectors determined this section of Inspection Procedure 71111.08 was not applicable.
b. Findings
No findings were identified.
1R11 Licensed Operator Requalification Program and Licensed Operator
Performance (71111.11)
.1 Review of Licensed Operator Requalification
a. Inspection Scope
On November 7, 2014, the inspectors observed the plant startup simulator training for an operating crew. The inspectors assessed the performance of the operators and the evaluators critique of their performance.
These activities constitute completion of one quarterly licensed operator requalification program sample, as defined in Inspection Procedure 71111.11.
b. Findings
No findings were identified.
.2 Review of Licensed Operator Performance
a. Inspection Scope
The inspectors observed the performance of on-shift licensed operators in the plants main control room. At the time of the observations, the plant was in a period of heightened activity or risk. The inspectors observed the operators performance of the following activities:
- September 24, 2014, train B emergency diesel generator 24-hour run
- October 11, 2014, plant shut down for refueling In addition, the inspectors assessed the operators adherence to plant procedures, including Procedure ODP-ZZ-00001, Operations Department - Code of Conduct, and other operations department policies.
These activities constitute completion of one quarterly licensed operator performance sample, as defined in Inspection Procedure 71111.11.
b. Findings
No findings were identified.
1R12 Maintenance Effectiveness
a. Inspection Scope
The inspectors reviewed two instances of degraded performance or condition of safety-related structures, systems, and components:
- September 13, 2014, train A emergency diesel generator jacket water leak
- October 17, 2014, train B control room air conditioning unit gasket failure The inspectors reviewed the extent of condition of possible common cause structures, systems, and component failures and evaluated the adequacy of the licensees corrective actions. The inspectors reviewed the licensees work practices to evaluate whether these may have played a role in the degradation of the structures, systems, and components. The inspectors assessed the licensees characterization of the degradation in accordance with 10 CFR 50.65 (the Maintenance Rule), and verified that the licensee was appropriately tracking degraded performance and conditions in accordance with the Maintenance Rule.
These activities constituted completion of two maintenance effectiveness samples, as defined in Inspection Procedure 71111.12.
b. Findings
Introduction.
The inspectors reviewed a Green self-revealing, non-cited violation of 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, for the licensees failure to correct a condition adverse to quality identified in safety related equipment installed in the plant. Specifically, following a failure of a gasket in 2013, the licensee identified that other safety related gaskets installed in the plant were installed incorrectly; however, no action was taken to correct this condition. As a result, during system testing, the train B control room air conditioning chiller units inlet end bell gasket extruded resulting in excess leakage.
Description.
On October 17, 2014, during the performance of train B engineered safety feature actuation system testing, a pressure transient caused by a pump start resulted in a leak on train B of the control room air conditioning system chiller end bell gasket. This leak was quantified as approximately 52 gallons per minute. The unit was isolated and Technical Specification 3.7.11, Condition A, was entered while repairs were completed.
It was restored to an operable condition within the time allowed by the technical specification action statement following replacement of the gasket.
The pressure transient exhibited during the testing was determined to be higher than normal system pressure due to the system alignment, but was still within design pressure and not significantly different than that which would be expected during an actual system actuation. As a result, the licensee reviewed the maintenance history of the unit and determined that gasket leakage had occurred on five occasions on this and similar units, dating back to 2007, during or soon after post-maintenance testing. This particular gasket had been installed under Preventative Maintenance Work Instruction 13511041 in August 2013.
In November 2013, after a failure of train B safety related switchgear chiller, a similar unit to the control room air conditioning chiller, Callaway Action Request 201308726 documented that the bolts fastening the chiller end bells were being torqued to 80 ft.-lbs.; however, this value appears to have no known technical basis. After researching the required compressive stress for the type of gaskets being used for these end bells, the licensee calculated that a torque value of 35 ft.-lbs should be used and changed their maintenance procedures to reflect this new value.
In February 2014, train A of the control room air conditioning system also experienced gasket leakage approximately six days after it had been replaced and torqued using the new specification of 35 ft.-lbs. After reviewing the skill of the craft versus the specificity of the work instructions, it was determined that extra procedural enhancements should be added to provide guidance on bolt tightening, use of lubricant, and prevention of contamination during the installation process. These were added to the corrective actions already developed for Callaway Action Request 201308726.
The licensee concluded that excessive bolting torque combined with inadequate skill of the craft and maintenance procedures on the part of the electrical maintenance technicians was leading to gasket unreliability and failures. After each of these instances of gasket failure, an extent of condition evaluation was completed that identified that this condition could exist in two safety related air conditioning units and two units that are important to safety. However, no immediate corrective actions or evaluations of whether the improperly installed gaskets constituted a degraded condition occurred. It was not until the pressure transient experienced during the testing in October 2014 that one of these susceptible gaskets failed during operation. The condition of the remaining improperly installed gasket was evaluated and operability justified in Callaway Action Request 201409335.
The licensee evaluated the impact of the gasket leak experienced on October 17, 2014, on the operability of the control room air conditioning system and the essential service water system. This evaluation concluded that the amount of leakage from the extruded gasket would not have threatened operability of the essential service water system. The amount of flow to the air conditioning unit also had enough margin to justify that it would have been able to perform its safety related function during an accident scenario. Based on this evaluation, the unit was deemed to have been operable but degraded during the period from August 2013 to October 2014.
Analysis.
The failure to correct a condition adverse to quality, identified in the plant, was a performance deficiency. Title 10 of the Code of Federal Regulations, Part 50, Appendix B, Criterion XVI, Corrective Action, requires that conditions adverse to quality are promptly identified and corrected. The licensee identified that the improperly installed safety related gaskets were subject to an increased failure rate, but failed to evaluate the impact or take prompt action to correct the condition. This performance deficiency is more than minor because it affected the equipment performance attribute of the Mitigating Systems Cornerstone objective to ensure the reliability of systems that respond to initiating events to prevent undesirable consequences. Specifically, during the period of November 2013 to October 2014, the failure to correct an improperly installed gasket on a control room air conditioning chiller unit resulted in reduced reliability of the safety related train. Using NRC Inspection Manual 0609, Appendix A, Exhibit 2, Mitigating Systems Screening Questions, the finding was determined to be of very low safety significance because it did not affect system design, did not result in a loss of system function, did not represent a loss of function of a single train for greater than its technical specifications allowed outage time, and did not cause the loss of function of one or more non-technical specification trains of equipment designated as high safety-significance.
This finding has an Evaluation cross-cutting aspect within the problem identification and resolution cross-cutting area because the licensee failed to thoroughly evaluate this issue to ensure that the resolution addressed the extent of condition commensurate with its safety significance. Specifically, the extent of condition was identified; however, no evaluation of the significance of the degraded condition was performed [P.2].
Enforcement.
Title 10 of the Code of Federal Regulations, Part 50, Appendix B, Criterion XVI, Corrective Action, requires, in part, that conditions adverse to quality, such as deficiencies, are promptly identified and corrected. Contrary to the above, from November 13, 2013, to October 17, 2014, the licensee failed to correct a condition adverse to quality. Specifically, Callaway Plant failed to take action to correct installed safety related gaskets in two safety related air conditioning system chillers that had been identified to have been improperly installed and were subject to failure, which constituted a condition adverse to quality. The licensee replaced the ruptured gasket and performed a new extent of condition evaluation for the remaining potentially improperly installed gasket. Because this violation was determined to be of very low safety significance (Green) and was entered into the licensees corrective action program as Callaway Action Request 201409335, this violation is being treated as a non-cited violation in accordance with Section 2.3.2.a of the NRC Enforcement Policy:
NCV 05000483/2014005-01, Failure to Correct a Condition Adverse to Quality on Safety Related Equipment.
1R13 Maintenance Risk Assessments and Emergent Work Control
a. Inspection Scope
The inspectors reviewed three risk assessments performed by the licensee prior to changes in plant configuration and the risk management actions taken by the licensee in response to elevated risk:
- October 21, 2014, yellow shutdown risk due to low reactor coolant system inventory
- October 27, 2014, yellow shutdown risk due to only one train of spent fuel pool cooling available The inspectors verified that these risk assessment were performed timely and in accordance with the requirements of 10 CFR 50.65 (the Maintenance Rule) and plant procedures. The inspectors reviewed the accuracy and completeness of the licensees risk assessments and verified that the licensee implemented appropriate risk management actions based on the result of the assessments.
Additionally, on October 29, 2014, the inspectors observed portions of one emergent work activity that had the potential to impact barrier integrity; a vendor crane malfunctioned with the old reactor vessel head suspended from the crane, Job 13004893.
The inspectors verified that the licensee appropriately developed and followed a work plan for these activities. The inspectors verified that the licensee took precautions to minimize the impact of the work activities on unaffected structures, systems, and components.
These activities constitute completion of three maintenance risk assessment and emergent work control inspection samples, as defined in Inspection Procedure 71111.13.
b. Findings
No findings were identified.
1R15 Operability Determinations and Functionality Assessments
a. Inspection Scope
The inspectors reviewed three operability determinations that the licensee performed for degraded or nonconforming structures, systems, or components:
- October 21, 2014, operability determination of residual heat removal system due to high vibrations on a vent pipe, Callaway Action Request 201407283
- October 22, 2014, operability determination of train B emergency diesel generator due to high vibrations on the train B essential service water pump, Callaway Action Request 201407444
- November 3, 2014, operability determination of train B emergency diesel generator intercooler due to the space bar having one missing locknut and one loose locknut, Callaway Action Request 201407779 The inspectors reviewed the timeliness and technical adequacy of the licensees evaluations. Where the licensee determined the degraded structures, systems, and components to be operable, the inspectors verified that the licensees compensatory measures were appropriate to provide reasonable assurance of operability. The inspectors verified that the licensee had considered the effect of other degraded conditions on the operability of the degraded structures, systems, and components.
These activities constitute completion of three operability and functionality review samples, as defined in Inspection Procedure 71111.15.
b. Findings
No findings were identified.
1R19 Post-Maintenance Testing
a. Inspection Scope
The inspectors reviewed four post-maintenance testing activities that affected risk-significant structures, systems, or components:
- November 6, 2014, train B essential service water piping replacement, Job 14003781
- November 6, 2014, train B emergency diesel generator maintenance outage, Job 13505272
- December 1, 2014, letdown system socket weld leak repair, Job 14006129
- December 4, 2014, motor-driven auxiliary feedwater pump flow control valve to steam generator D repairs, Job 14006195 The inspectors reviewed licensing- and design-basis documents for the structures, systems, and components and the maintenance and post-maintenance test procedures.
The inspectors observed the performance of the post-maintenance tests to verify that the licensee performed the tests in accordance with approved procedures, satisfied the established acceptance criteria, and restored the operability of the affected structures, systems, and components.
These activities constitute completion of four post-maintenance testing inspection samples, as defined in Inspection Procedure 71111.19.
b. Findings
No findings were identified.
1R20 Refueling and Other Outage Activities
.1 Refueling Outage Activities
a. Inspection Scope
During the stations refueling outage that concluded on November 22, 2014, the inspectors evaluated the licensees outage activities. The inspectors verified that the licensee considered risk in developing and implementing the outage plan, appropriately managed personnel fatigue, and developed mitigation strategies for losses of key safety functions. This verification included the following:
- Review of the licensees outage plan prior to the outage
- Monitoring of shut-down and cool-down activities
- Verification that the licensee maintained defense-in-depth during outage activities
- Observation and review of reduced-inventory activities
- Observation and review of fuel handling activities
- Monitoring of heat-up and startup activities These activities constitute completion of one refueling outage sample, as defined in Inspection Procedure 71111.20.
b. Findings
No findings were identified.
.2 Other Outage Activities
a. Inspection Scope
The inspectors evaluated outage activities for an unplanned outage that began on December 3, 2014, and continued through December 6. The inspectors reviewed activities to ensure that the licensee considered risk in developing, planning, and implementing the outage schedule. The inspectors also confirmed that the licensee scheduled covered workers such that the minimum days off for individuals working on outage activities were in compliance with 10 CFR 26.205(d)(4) and (5).
The outage was caused when a ground occurred in the main generator exciter transformer. This caused a lockout of the main generator that opened both of the main generator output breakers, which resulted in a trip of the main turbine and an automatic trip of the reactor.
During the outage, the inspectors observed portions of the shutdown and monitored licensee controls over the outage activities listed below.
- Clearance activities, including confirmation that tags were properly hung and equipment appropriately configured to safely support the work or testing
- Status and configuration of systems to ensure that technical specifications were met
- Management of fatigue
- Licensee identification and resolution of problems related to outage activities
- Startup and ascension to full power operation and tracking of startup prerequisites These activities constitute completion of one outage activities sample, as defined in Inspection Procedure 71111.20.
1R22 Surveillance Testing
a. Inspection Scope
The inspectors observed eight risk-significant surveillance tests and reviewed test results to verify that these tests adequately demonstrated that the structures, systems, and components were capable of performing their safety functions:
In-service tests:
- November 25, 2014, train A safety injection pump and valve testing, Job 14508849 Reactor coolant system leak detection tests:
- November 29, 2014, reactor coolant system inventory balance Other surveillance tests:
- September 24, 2014, train B emergency diesel generator 24-hour run, Job 13503949
- October 8, 2014, simultaneous start of both emergency diesel generators, Job 08502992
- October 11, 2014, main turbine overspeed testing, Job 13506675
- October 14, 2014, containment integrated leak rate test, Job 04501245
- October 17, 2014, train A and B engineered safety features actuation system testing, Job 13506547
- November 21, 2014, low power physics testing, Job 13508126 The inspectors verified that these tests met technical specification requirements, that the licensee performed the tests in accordance with their procedures, and that the results of the test satisfied appropriate acceptance criteria. The inspectors verified that the licensee restored the operability of the affected structures, systems, and components following testing.
These activities constitute completion of eight surveillance testing inspection samples, as defined in Inspection Procedure 71111.22.
b. Findings
No findings were identified.
Cornerstone: Emergency Preparedness
1EP4 Emergency Action Level and Emergency Plan Changes
a. Inspection Scope
The inspectors performed an in-office review of the Callaway Plant Radiological Emergency Response Plan, Revision 45, and Procedure EIP-ZZ-00212, Protective Action Recommendations, Revision 26. These revisions,
- Changed the description of the licensees dose assessment model from a straight-line Gaussian to a variable trajectory model
- Deleted evacuation time estimates from Procedure EIP-ZZ-00212
- Deleted MAGNEM as the licensees primary method of radiological assessment
- Implemented the Unified RASCAL dose assessment program as the licensees primary method of radiological assessment These revisions were compared to their previous revisions, to the criteria of NUREG-0654, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants, Revision 1, and to the standards in 10 CFR 50.47(b) to determine if the revisions adequately implemented the requirements of 10 CFR 50.54(q)(3) and 50.54(q)(4). The inspectors verified that the revisions did not decrease the effectiveness of the emergency plan.
This review was not documented in a safety evaluation report and did not constitute approval of licensee-generated changes; therefore, these revisions are subject to future inspection.
These activities constitute completion of two emergency action level and emergency plan changes samples as defined in Inspection Procedure 71114.04.
b. Findings
No findings were identified.
RADIATION SAFETY
Cornerstones: Public Radiation Safety and Occupational Radiation Safety
2RS1 Radiological Hazard Assessment and Exposure Controls
a. Inspection Scope
The inspectors assessed the licensees performance in assessing the radiological hazards in the workplace associated with licensed activities. The inspectors assessed the licensees implementation of appropriate radiation monitoring and exposure control measures for both individual and collective exposures. The inspectors walked down various portions of the plant and performed independent radiation dose rate measurements. The inspectors interviewed the radiation protection manager, radiation protection supervisors, and radiation workers. The inspectors reviewed licensee performance in the following areas:
- The hazard assessment program, including a review of the licensees evaluations of changes in plant operations and radiological surveys to detect dose rates, airborne radioactivity, and surface contamination levels
- Instructions and notices to workers, including labeling or marking containers of radioactive material, radiation work permits, actions for electronic dosimeter alarms, and changes to radiological conditions
- Programs and processes for control of sealed sources and release of potentially contaminated material from the radiologically controlled area, including survey performance, instrument sensitivity, release criteria, procedural guidance, and sealed source accountability
- Radiological hazards control and work coverage, including the adequacy of surveys, radiation protection job coverage and contamination controls, the use of electronic dosimeters in high noise areas, dosimetry placement, airborne radioactivity monitoring, controls for highly activated or contaminated materials (non-fuel) stored within spent fuel and other storage pools, and posting and physical controls for high radiation areas and very high radiation areas
- Radiation worker and radiation protection technician performance with respect to radiation protection work requirements
- Audits, self-assessments, and corrective action documents related to radiological hazard assessment and exposure controls since the last inspection These activities constitute completion of one sample of radiological hazard assessment and exposure controls as defined in Inspection Procedure 71124.01.
b. Findings
No findings were identified.
2RS3 In-plant Airborne Radioactivity Control and Mitigation
a. Inspection Scope
The inspectors evaluated whether the licensee controlled in-plant airborne radioactivity concentrations consistent with ALARA principles and that the use of respiratory protection devices did not pose an undue risk to the wearer. During the inspection, the inspectors interviewed licensee personnel, walked down various portions of the plant, and reviewed licensee performance in the following areas:
- The licensees use, when applicable, of ventilation systems as part of its engineering controls
- The licensees respiratory protection program for use, storage, maintenance, and quality assurance of National Institute for Occupational Safety and Health-certified equipment, qualification and training of personnel, and user performance
- The licensees capability for refilling and transporting self-contained breathing apparatus air bottles to and from the control room and operations support center during emergency conditions, status of self-contained breathing apparatus staged and ready for use in the plant and associated surveillance records, and personnel qualification and training
- Audits, self-assessments, and corrective action documents related to in-plant airborne radioactivity control and mitigation since the last inspection These activities constitute completion of one sample of in-plant airborne radioactivity control and mitigation as defined in Inspection Procedure 71124.03.
b. Findings
No findings were identified.
OTHER ACTIVITIES
Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity, Emergency Preparedness, Public Radiation Safety, Occupational Radiation Safety, and Security
4OA1 Performance Indicator Verification
.1 Mitigating Systems Performance Index: High Pressure Injection Systems (MS07)
a. Inspection Scope
The inspectors reviewed the licensees mitigating system performance index data for the period of fourth quarter 2013 through third quarter 2014 to verify the accuracy and completeness of the reported data. The inspectors used definitions and guidance contained in Nuclear Energy Institute Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7, to determine the accuracy of the reported data.
These activities constituted verification of the mitigating system performance index for high pressure injection systems, as defined in Inspection Procedure 71151.
b. Findings
No findings were identified.
.2 Mitigating Systems Performance Index: Residual Heat Removal Systems (MS09)
a. Inspection Scope
The inspectors reviewed the licensees mitigating system performance index data for the period of fourth quarter 2013 through third quarter 2014 to verify the accuracy and completeness of the reported data. The inspectors used definitions and guidance contained in Nuclear Energy Institute Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7, to determine the accuracy of the reported data.
These activities constituted verification of the mitigating system performance index for residual heat removal systems, as defined in Inspection Procedure 71151.
b. Findings
No findings were identified.
.3 Occupational Exposure Control Effectiveness (OR01)
a. Inspection Scope
The inspectors verified that there were no unplanned exposures and or losses of radiological control over locked high radiation areas and very high radiation areas during the period of second quarter 2013 through third quarter 2014. The inspectors reviewed a sample of radiologically controlled area exit transactions showing exposures greater than 100 mrem. The inspectors used definitions and guidance contained in Nuclear Energy Institute Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7, to determine the accuracy of the reported data.
These activities constituted verification of the occupational exposure control effectiveness performance indicator as defined in Inspection Procedure 71151.
b. Findings
No findings were identified.
.4 Radiological Effluent Technical Specifications/Offsite Dose Calculation Manual
Radiological Effluent Occurrences (PR01)
a. Inspection Scope
The inspectors reviewed corrective action program records for liquid or gaseous effluent releases that occurred from second quarter 2013 through third quarter 2014, and were reported to the NRC to verify the performance indicator data. The inspectors used definitions and guidance contained in Nuclear Energy Institute Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7, to determine the accuracy of the reported data.
These activities constituted verification of the radiological effluent technical specification/offsite dose calculation manual radiological effluent occurrences performance indicator as defined in Inspection Procedure 71151.
b. Findings
No findings were identified.
4OA2 Problem Identification and Resolution
.1 Routine Review
a. Inspection Scope
Throughout the inspection period, the inspectors performed daily reviews of items entered into the licensees corrective action program and periodically attended the licensees condition report screening meetings. The inspectors verified that licensee personnel were identifying problems at an appropriate threshold and entering these problems into the corrective action program for resolution. The inspectors verified that the licensee developed and implemented corrective actions commensurate with the significance of the problems identified. The inspectors also reviewed the licensees problem identification and resolution activities during the performance of the other inspection activities documented in this report.
b. Findings
No findings were identified.
.2 Semiannual Trend Review
a. Inspection Scope
The inspectors reviewed the licensees corrective action program, performance indicators, system health reports, and other documentation to identify trends that might indicate the existence of a more significant safety issue. The inspectors verified that the licensee was taking corrective actions to address identified adverse trends.
These activities constitute completion of one semiannual trend review sample, as defined in Inspection Procedure 71152.
b. Observations and Assessments The inspectors noted the following negative trends: an increasing number of missed or late hourly fire watch checks and inconsistent use of written instructions by the maintenance department. The inspectors verified that the licensee was aware of these issues and these issues have been entered into the corrective action program.
c. Findings
No findings were identified.
.3 Annual Follow-up of Selected Issues
a. Inspection Scope
On November 18, 2014, the inspectors selected Callaway Action Request 201408530, which identified that, contrary to technical specifications, multiple safety injection accumulator outlet valve breakers were closed at the same time, for an in-depth follow-up. The inspectors assessed the licensees problem identification threshold, cause analyses, extent of condition reviews and compensatory actions. The inspectors verified that the licensee appropriately prioritized the planned corrective actions and that these actions were adequate to correct the condition and prevent recurrence. A licensee-identified violation associated with this issue is described in Section 4OA7.
The inspectors also assessed the licensees implementation of their process used to identify, document, track, and resolve operational challenges. Inspection activities included, but were not limited to, a review of the cumulative effects of the operator workarounds on system availability and the potential for improper operation of the system, for potential impacts on multiple systems, and on the ability of operators to respond to plant transients or accidents.
The inspectors performed a review of the cumulative effects of operator workarounds.
The documents listed in the attachment were reviewed to accomplish the objectives of the inspection procedure. The inspectors reviewed both current and historical operational challenge records to determine whether the licensee was identifying operator challenges at an appropriate threshold, had entered them into their corrective action program, and proposed or implemented appropriate and timely corrective actions that addressed each issue. Reviews were conducted to determine if any operator challenge could increase the possibility of an initiating event, if the challenge was contrary to training, required a change from long-standing operational practices, or created the potential for inappropriate compensatory actions. Daily plant and equipment status logs, degraded instrument logs, and operator aids or tools being used to compensate for material deficiencies were also assessed to identify any potential sources of unidentified operator workarounds.
These activities constitute completion of two annual follow-up samples, which included one operator work-around sample, as defined in Inspection Procedure 71152.
b. Findings
No findings were identified.
4OA3 Follow-up of Events and Notices of Enforcement Discretion
On December 3, 2014, at 12:33 a.m., the Callaway plant tripped. A cable located inside the main generator exciter transformer shorted against the core of the transformer. This caused the main generator lockout relays to actuate and the immediate opening of the two output breakers that transmit the electricity from the main generator to the grid.
Protective relays caused the main turbine to trip offline and the reactor to shut down as designed.
The NRC resident inspectors responded to the plant to review plant status, communicate the event to supervision, evaluate performance of operators and mitigating systems, and ensure proper licensee actions and evaluation of event classifications.
These activities constitute completion of one event follow-up sample, as defined in Inspection Procedure 71153.
4OA5 Other Activities
Reactor Vessel Head Replacement
a. Inspection Scope
1. Design and Planning Inspections
The inspectors used the guidance in Inspection Procedure 71007, Reactor Vessel Head Replacement Inspection, to perform the following reactor vessel head design and planning inspection activities.
Engineering and Technical Support The inspectors reviewed engineering and technical support activities performed prior to, and during, the reactor vessel head replacement outage. This review verified that selected design changes and modifications to structures, systems, and components described in the Final Safety Analysis Report for transporting the new and old reactor vessel heads were reviewed in accordance with 10 CFR 50.59. Additionally, key design aspects and modifications associated with the reactor vessel head replacement were also reviewed.
Lifting and Rigging The inspectors reviewed engineering design, modification, and analysis associated with reactor vessel head lifting and rigging activities. This included:
- (1) crane and rigging equipment;
- (2) reactor vessel head component drop analysis;
- (3) safe load paths; and
- (4) load laydown areas.
Radiation Protection The inspectors reviewed radiation protection program controls, planning, and preparation in:
- (1) as low as is reasonably achievable (ALARA) planning;
- (2) dose estimates and tracking;
- (3) exposure and contamination controls;
- (4) radioactive material management;
- (5) radiological work plans and controls;
- (6) emergency contingencies; and
- (7) project staffing and training plans. This review was performed in conjunction with the baseline inspections conducted during Refueling Outage 20.
Security Considerations The inspectors observed security controls and reviewed security plans to verify that any potential adverse impacts were minimized. The inspectors made frequent observations of security actions to verify that the licensee had implemented the appropriate controls for affected vital and protected area barriers during the reactor head replacement activities.
2. Reactor Vessel Head Fabrication Inspections at Licensee Facility
The inspectors used the guidance in Inspection Procedure 71007, Reactor Vessel Head Replacement Inspection, to perform the following reactor vessel head fabrication inspection activities.
Heat Treatment The inspectors verified that the material heat treatment used to enhance the mechanical properties of the reactor vessel head material carbon, low alloy, and high alloy chromium steels was conducted per ASME code and approved vendor procedures consistent with the applicable ASME Code,Section III, requirements. Also, the inspectors reviewed the heat treatment procedures to assure that requirements associated with the following areas were met:
- (1) furnace atmosphere;
- (2) furnace temperature distribution and calibration of measuring and recording devices;
- (3) thermocouple installation;
- (4) heating and cooling rates;
- (5) quenching methods; and
- (6) record and documentation requirements.
Nondestructive Examination (NDE)
Inspections were conducted to ensure the manufacturing control plan included provisions for monitoring NDE to ascertain that the NDE was performed in accordance with applicable code, material specification, and contract requirements.
Welding The inspectors reviewed the documentation for the weld overlay welding operations that established a layer of stainless steel cladding on the inside of the reactor vessel head to determine if it was accomplished per design. The inspectors also selected a sample of control rod drive mechanism flange-to-nozzle welds and reviewed the following items:
- (1) certified mill test reports of the flange, weld material rods, and control rod drive mechanism nozzles;
- (2) certified mill test reports for the welding material for the reactor vessel head cladding;
- (3) cladding weld records, weld rod material control requisitions, traceability of weld material rods, weld procedure qualification, welder qualifications, and nonconformance reports;
- (4) control rod drive mechanism nozzle cladding welding inspection records, weld rod material control requisitions, traceability of weld material rods, weld procedure qualification, welder qualifications, and nonconformance reports;
- (5) control rod drive mechanism to nozzle welding and welds inspection records, weld rod material control requisitions, traceability of weld material rods, weld procedure qualification, welder qualifications, and nonconformance reports; and
- (6) NDE procedures, NDE records of the welds, NDE personnel qualifications, and certification of the NDE solvents.
Procedures Inspectors verified that repair procedures had been established and that these procedures were consistent with applicable ASME code, material specification, and contract requirements by verifying:
- (1) repair welding was conducted in accordance with procedures qualified to Section IX of the ASME code;
- (2) all welders had been qualified in accordance with Section IX of the ASME code;
- (3) records of repairs were maintained; and
- (4) that requirements had been established for the preparation of certified material test reports and that the records of all required examinations and tests were traceable to the procedures to which they were performed.
Code Reconciliation The inspectors reviewed the required documentation, supplemental examinations, analysis, and ASME code documentation reconciliation to ensure that the original ASME code N-Stamp remains valid, and that the replacement head complies with appropriate NRC rules and industry requirements. The inspectors also ensured that the design specification was reconciled and a design report was prepared for the reconciliation of the replacement head, verifying that they were certified by professional engineers competent in ASME code requirements.
Quality Assurance Program The inspectors verified that:
- (1) machining was carried out under a controlled system of operation;
- (2) a drawing/document control system was in use in the manufacturing process; and
- (3) part identification and traceability was maintained throughout processing and was consistent with the manufacturers quality assurance program.
Compliance Inspection The inspectors verified that the original ASME Code,Section III, data packages for the replacement reactor vessel head were supplemented by documents included in the ASME Code,Section XI, (pre-service inspection) data packages. The inspectors examined selected manufacturing and inspection records of the finished machined reactor vessel head and verified compliance with applicable documentation requirements.
3. Reactor Vessel Head Removal and Replacement Inspections
The inspectors used the guidance in Inspection Procedure 71007, Reactor Vessel Head Replacement Inspection, to perform the following reactor vessel head removal and replacement inspection activities:
Lifting and Rigging The inspectors reviewed preparations and procedures for rigging and heavy lifting including crane and rigging inspections, testing, equipment modifications, laydown area preparations, and training for the following activities:
- Area preparation for the outside systems
- Lattice boom crawler crane assembly, disassembly, and operation
- Hydraulic gantry lift system
- Outside bridge and trolley transfer system
- Elevated cantilevered handling device installation and use
- Reactor vessel head lift rig and polar crane
- Downender/upender fixture
- Old reactor vessel head removal
- New reactor vessel head placement
- Transport of old reactor vessel head to storage location Major Structural Modifications The inspectors reviewed and observed portions of the one structural modification made to facilitate reactor vessel head replacement. Specifically, the inspectors reviewed the engineering documents associated with the removal of a portion of wall in containment.
The change in design of the reactor head package made the portion of wall removed from containment unnecessary. The inspectors reviewed the design change associated with this modification.
Containment Access and Integrity The inspectors observed there were no modifications to the existing containment access structure or integrity to allow for the reactor vessel head to be removed and installed.
The new and old reactor vessel head were moved in and out of containment using the existing equipment hatch.
Outage Operating Conditions The inspectors reviewed and observed the establishment of operating conditions including:
- (1) defueling;
- (2) reactor coolant system draindown;
- (3) system isolation;
- (4) safety tagging;
- (5) radiation protection controls;
- (6) controls for excluding foreign materials in the reactor vessel;
- (7) verification of the suitability of reinstalled (reused)components for use; and
- (8) the installation, use, and removal of temporary services.
Section 1R20 of this report documents additional activities that were performed during the outage.
Storage of Removed Reactor Vessel Head The inspectors reviewed the radiological safety plans and observed the transport, storage, and radiological surveys of the old reactor vessel head to its onsite storage location. The inspectors assessed licensee performance with respect to maintaining occupational individual and collective radiation exposures as low as is reasonably achievable with respect to the reactor vessel head replacement. During the inspection, the inspectors interviewed licensee personnel and reviewed licensee performance in the following areas:
- ALARA work activity plans and evaluations, in-progress reviews, exposure estimates, and exposure mitigation requirements
- Radiation worker and radiation protection technician performance during work activities in radiation areas and high radiation areas
Reactor Vessel Head Post Installation Verification and Testing Inspections The inspectors used the guidance in Inspection Procedure 71007, Reactor Vessel Head Replacement Inspection, to perform the following post-installation verification and testing inspection activities. Selective inspections were performed of the following areas:
- (1) containment testing;
- (2) licensees post-installation inspections and verifications program and its implementation;
- (3) reactor coolant system leakage testing and review of test results;
- (4) procedures required for equipment performance testing to confirm the design and to establish baseline measurements; and
- (5) pre-service inspection of new welds.
b. Findings
No findings were identified.
4OA6 Meetings, Including Exit
Exit Meeting Summary
On October 31, 2014, the inspectors presented the radiation safety inspection results to Mr. D. Neterer, Vice President, Nuclear Operations, and other members of the licensee staff.
The licensee acknowledged the issues presented. The licensee confirmed that any proprietary information reviewed by the inspectors had been returned or destroyed.
On November 20, 2014, the inspectors presented the inservice inspection results to Ms. S. Banker, Senior Director of Executive Projects, and other members of the licensee staff.
The licensee acknowledged the issues presented. The licensee confirmed that any proprietary information reviewed by the inspectors had been returned or destroyed.
On November 20, 2014, the inspectors presented the reactor vessel head inspection results to Ms. S. Banker, Senior Director of Executive Projects, and other members of the licensee staff.
The licensee acknowledged the issues presented. The licensee confirmed that any proprietary information reviewed by the inspectors had been returned or destroyed.
On January 5, 2014, the inspectors conducted a telephonic exit meeting to present the results of the in-office inspection of changes to the licensees emergency plan to Mr. P. McKenna, Manager, Emergency Preparedness, and other members of the licensee staff. The licensee acknowledged the issues presented. The licensee confirmed that any proprietary information reviewed by the inspectors had been returned or destroyed.
On January 7, 2015, the resident inspectors presented the inspection results to Mr. F. Diya, Senior Vice President and Chief Nuclear Officer, and other members of the licensee staff. The licensee acknowledged the issues presented. The licensee confirmed that any proprietary information reviewed by the inspectors had been returned or destroyed.
4OA7 Licensee-Identified Violations
The following violations of very low safety significance (Green) were identified by the licensee and are violations of NRC requirements which meet the criteria of the NRC Enforcement Policy for being dispositioned as non-cited violations.
- Title 10 of the Code of Federal Regulations, Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, requires, in part, that activities affecting quality be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances, and shall be accomplished in accordance with these instructions, procedures, and drawings. Attachment 3 of Callaway Procedure APA-ZZ-01400, Appendix K, Tools for Event Prevention, is a procedure that affects quality. It states that workers shall identify conditions on a jobsite such as sensitive equipment in the work area, and continues on to state the worker needs to eliminate hazards, install appropriate barriers, or develop contingencies before proceeding with the task. Contrary to the above, on September 12, 2014, the licensee failed to accomplish an activity affecting quality in accordance with procedures.
Specifically, maintenance technicians failed to follow Procedure APA-ZZ-01400, Appendix K, and identify that train A emergency diesel generator jacket water heater outlet relief valve was sensitive equipment in that it was a valve that could be accidentally repositioned if working in the area. As a result, they failed to protect the valve from inadvertent operation. During maintenance, the valve was bumped out of position during maintenance work, causing the jacket water system to slowly leak and rendered the diesel inoperable for approximately 25 hours2.893519e-4 days <br />0.00694 hours <br />4.133598e-5 weeks <br />9.5125e-6 months <br /> before being identified by operations personnel. Using NRC Inspection Manual 0609, Appendix A, Exhibit 2, Mitigating Systems Screening Questions, the finding was determined to be of very low safety significance because it did not affect the design of the system, did not result in a loss of system function, did not represent a loss of function of a single train for greater than its technical specifications allowed outage time, and did not cause the loss of function of one or more non-technical specification trains of equipment designated as high safety-significance. This violation was entered into the licensees corrective action program as Callaway Action Request 201406128.
- Technical Specification 5.4.1.a states, in part, that written procedures shall be established, implemented, and maintained covering the applicable procedures in Regulatory Guide 1.33, Quality Assurance Program Requirements, Revision 2, Appendix A, February 1978.
NRC Regulatory Guide 1.33, Appendix A, Section 1.d. requires procedures for Procedure Adherence and Temporary Change Method.
Procedure APA-ZZ-00100, Written Instructions Use and Adherence, Revision 32, a procedure intended to meet the above requirements, Section 4.1, Rules for Written Instructions, states in part, 4.1.8. Perform procedures or written instructions in the following manner:
- Numbered or lettered steps are performed in sequence 4.1.9. Sections of a procedure or work instruction may be performed out of sequence or concurrently if allowed by the document. Steps within a section MUST be performed in the order written.
Additionally, for procedures identified as Continuous Use, it states in part, 4.6.2.c. Perform the step as written in the sequence specified.
Contrary to the above, on November 18, 2014, the licensee failed to implement a procedure required by Technical Specification 5.4.1.a. Specifically, a licensed operator failed to comply with Sections 4.1 and 4.6 of Procedure APA-ZZ-00100 when he entered multiple sections of Procedure OSP-BB-VL006, RCS Pressure Isolation Valves Inservice Tests - IPTE, which was not allowed by the document. The operator directed the closing of the breakers for all four safety injection accumulator isolation valves at the same time when the procedure directed testing one valve at a time and restoring after each test.
Using NRC Inspection Manual 0609, Appendix A, Exhibit 2, Mitigating Systems Screening Questions, the finding was determined to be of very low safety significance because it did not affect the design or qualification of a system, did not result in a loss of system function, did not represent a loss of function of a single train for greater than its technical specifications allowed outage time, and did not cause the loss of function of one or more non-technical specification trains of equipment designated as high safety-significance. This violation was entered into the licensees corrective action program as Callaway Action Request 201408530.
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee Personnel
- S. Abel, Director, Engineering Projects
- S. Banker, Senior Director, Executive Projects
- F. Bianco, Assistant Operations Manager, Shift
- R. Davis, Welding Engineer, Nuclear Engineering
- F. Diya, Senior Vice President and Chief Nuclear Officer
- J. Doughty, ISI Program Owner
- G. Forster, NDE Level III
- K. Gilliam, Supervisor, Radiation Protection
- C. Graham II, Health Physicist, Radiation Protection
- J. Heithold, Career Engineer, Major Modifications
- A. King, Health Physicist, Radiation Protection
- J. Kovar, Licensing Engineer
- G. Kremer, Director, Engineering Programs
- P. McKenna, Manager, Emergency Preparedness
- V. Miller, Supervising Health Physicist, Radiation Protection
- W. Moskopf, Project Manager, Replacement Reactor Vessel Closure Head
- D. Neterer, Vice President, Nuclear Operations
- J. Nurrenbern, Boric Acid Corrosion Control Program Manager
- S. Petzel, Licensing Engineer, Regulatory Affairs
- C. Smith, Manager, Radiation Protection
- D. Thompson, Health Physicist, Radiation Protection
- T. Witt, Licensing Engineer, Regulatory Affairs
LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
Opened and Closed
- 05000483/2014005-01 NCV Failure to Correct a Condition Adverse to Quality on Safety Related Equipment (Section 1R12)